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Portugal Golden Visa: how to obtain a residence permit under the investment fund option

Brittany Collins - head of legal department

The Golden Visa program in Portugal has undergone significant changes in 2023 as it is no longer possible to invest in real estate or make a capital transfer to be eligible for a residence permit.

Other options, however, remain available. Investment fund units are one of them, and it has been growing more popular in previous years even before the changes imposed.

Portugal Golden Visa: how to obtain a residence permit under the investment fund option

What is a Portugal Golden Visa investment fund?

Participating in an investment fund is one of the remaining options for investors to apply for the Portugal Golden Visa.

An investment fund is generally a pool of money collected from multiple participants to invest in various projects for profit. The pool is overseen by a managing company that decides where the funds will be allocated, depending on their strategy and field of expertise and the level of risk set by the investors.

To be eligible for the Portugal Golden Visa program by investing in fund units, the minimum investment is €500,000. The funds can accept lower investments, but they will not serve the purposes of the Golden Visa program in that case.

Who is eligible for a Portugal Golden Visa by investing in funds?

All potential Portugal Golden Visa applicants willing to take the investment fund route must meet the following requirements:

  • be a non-EU, non-EEA and non-Swiss citizen;

  • be over 18 years old;

  • have a clean criminal record;

  • have no socially dangerous diseases;

  • have medical insurance with full coverage.

Some investment funds may have extra requirements for the applicants:

  • have a certain level of knowledge about financial instruments, such as company stock, government bonds, funds, etc.;

  • proof of substantial legal funds for investment.

The main applicant can include the following family members in the application for a residence permit by investment:

  • spouse or legal partner;

  • children under 18 years of age;

  • children over 18 years of age who are single, financially dependent on the investor and enrolled as full-time students;

  • parents of the investor and their spouse. If they are under 65 years old, they must be financially dependent on the investor.

5 benefits of getting a Portugal Golden Visa by investment funds

1. Diversification. Applicants are allowed to divide their €500,000 investment into several funds. Besides, the funds themselves are regulated to have a certain level of diversification in their strategy. It helps mitigate risks for the participating investors.

2. Safety. All the investment funds approved for the Portugal Golden Visa program are regulated by the Portuguese Securities Market Commission (CMVM) and by the country’s Central Bank. The rules stipulate that the Portuguese Tax and Customs Authority regularly audits fund managers. Such a high level of control ensures that all the funds must comply with the country’s laws.

3. Tax optimisation. The investor does not need to pay dividends and capital gains tax if they don’t become a tax resident in Portugal after obtaining a residence permit.

4. The potential of high return. The annual yields from the investment funds can be higher than income from other forms of investment eligible for the Portugal Golden Visa. Most investment funds qualified for the program target an annual internal return rate (IRR) of 10—20%.

5. Professional management. After investing the money into fund units, the Portugal Golden Visa applicant allows a team of experts to manage all the transactions until the time comes to exit the fund.

Number of approved Portugal Golden Visa applications through investment funds

Investment funds was an increasingly popular choice for Portugal Golden Visa applicants even before the law changes

5 disadvantages of getting a Portugal Golden Visa by investment funds

1. Risks. Investors who choose the investment fund as their option to obtain a Portugal Golden Visa are not guaranteed profit from their participation in it. While the fund manager is motivated to get a profit and earn their commission, investors alone bear the consequences if the value of their investment fund units depreciates by the time of their exit.

2. Lack of control. While some investors may be happy to allow a third party to manage their investment, it can be uncomfortable for others who prefer to keep their funds under full control. Ultimately, it comes down to trust between the investor and their fund manager.

3. Sharing profits. Any potential yields will be divided between the investors and the fund managers who take their commission. It can vary between funds but is normally at over 5% of all the profit generated by investment. Besides, most funds charge a subscription fee and an annual management fee.

4. Exit issues. Most investment funds contractually ensure the participants that the fund will not be dissolved before a certain period. Usually, it extends beyond five years, when the Portugal Golden Visa holders can obtain permanent residency in the country or its citizenship.

The investors’ funds are tied until the fund dissolves, making the fund units' resale very difficult. Funds can also trigger extension periods without consulting the investors.

5. KYC requirements. Know Your Client is a standard practice in the investment and financial services industry, suggesting that investors present documents confirming the income, source, and legality.

Portugal Golden Visa investment funds: list of options

After the changes to the Portugal Golden Visa program, real estate purchase is no longer an option for the applicants.

Investment funds that are directly or indirectly related to real estate are also not eligible for those who want to obtain Portugal residency by investment. However, there are plenty of investment funds specialising in other fields, including technology, agriculture, and environment (ESG).

All the funds listed below are certified by the Portuguese Securities Market Commission, known in Portuguese as Comissao do Mercado de Valores Mobiliários (CMVM).

Investment funds eligible for the Portugal Golden Visa Program

Fund name

Lifecycle (years)

Targeted IRR per year

Mgmt. fee per year

Subscription fee

Asset classes

Pela Terra

7

10%

0.95%

1%

Agriculture

Iberis Bluetech

8

15%

0.5%

3%

Technology

Terra Nova

8

8%

1.5%

1.5%

Healthcare, ESG, startups

ActiveCap Opportunities

10

13%

2%

2%

ESG

Aretha Portugal Vision

10

10%

0.67%

0%

Mixed

Growth Iberia

10

20%

2%

2%

Mixed

MedCapital

10

20%

2%

1%

Healthcare

Marcha VC Fund

14

10%

3%

0%

Mixed

Optimize Portugal Golden Opportunities

Open-ended

1.8%

1%

Equities, bonds

Saratoga

Open-ended

6%

0.55%

0%

ESG

In case of open-ended investment funds, the investor can make an exit at any moment without barriers. However, to qualify for the Portugal Golden Visa, they must maintain a holding period of five years.

Documents required to participate in investment funds for Portugal Golden Visa

Any investor willing to participate in the Portugal Golden Visa program must submit a minimal set of documents:

  • passport and its copy;

  • bank statements confirming substantial funds;

  • proof of tax identification number in your country of origin or residence;

  • proof of medical insurance;

  • clean criminal record certificate;

  • declaration of honour to confirm the intention to maintain investment for at least 5 years.

Share of approved Portugal Golden Visa applications by asset class

Real estate purchase and capital transfer are not viable option for Golden Visa applicants since October 2023, making investment funds the most popular remaining alternative

Applying for Portugal Golden Visa by investment fund: a step-by-step guide

The whole process of obtaining a residence permit in Portugal can take between 8 and 10 months. Almost all the steps can be done remotely, and the investor’s presence is required only on two occasions.

1

2 weeks

Choosing the type of investment

Investment fund units are not the only option to obtain residency in Portugal. The applicants can also choose to support art and cultural heritage, scientific research or local business. They don’t need to travel to Portugal at this stage.

2

1—2 weeks

Obtaining an individual taxpayer number

Each potential investor receives a nine-digit taxpayer number (NIF) to perform any official or financial activity in Portugal. The procedure can be done remotely or in person.

3

1+ month

Setting up a bank account in Portugal

With your individual taxpayer number, the investor is able to open a bank account in a Portuguese bank. The investor needs to do it for future transactions. To open the account, one visits a Portuguese bank office.

4

3—4 weeks

Fulfilling the investment condition

The investor transfers the money to the Portuguese bank account and then redirects it to the investment fund of their choice.

5

1—2 weeks

Collecting the required documents and submitting the application

The investor receives the full list of documents required to apply for a residence permit. The documents' electronic copies are sent to the Agency for Integration, Migration and Asylum (AIMA).

6

4—5 months

Application processing

AIMA verifies all the documents submitted by the applicant and delivers the verdict.

7

1—2 weeks

Submission of biometric data

The investor and other family members in the application travel to Portugal to submit original documents and fingerprints for residence permit cards. The appointment must be made in advance.

8

4—6 months

Issuance of residence permit cards

The investor’s documents are examined once again. If the application receives the final approval, the applicant pays the fee for the residence permit cards, which are prepared within two weeks.

Key takeaways

  1. An investor can become a Portugal resident by contributing to an investment fund qualified for the Portugal Golden Visa program.

  2. The minimum investment is €500,000, which can be spread across several investment funds. Receiving Portugal permanent residency or citizenship takes five years after obtaining the Golden Visa, but the investment will likely be tied to the funds for a few more years.

  3. Purchasing investment fund units is a high-risk, high-reward option. The investor can earn a more significant profit from it than if another investment option is chosen, but there’s also a likelihood that the investment value will depreciate.

  4. A Portugal Golden Visa-qualified investment fund cannot specialise in real estate. However, they can invest in agricultural, environmental or other types of projects to be a Portugal Golden Visa option.

  5. The Portugal Golden Visa allows the investor to reside in Portugal and obtain the country’s citizenship in 5 years.

Frequently asked questions

  • How much do I need to put in for investment funds for the Portugal Golden Visa?

    Investment funds have different thresholds for participants. However, the minimum investment to qualify for the Golden Visa program is €500,000, which is more than required by the funds.

  • Is it possible to invest in different Portuguese investment funds?

    Yes, the investment can be spread across several funds, but it should amount to a total of €500,000 to be eligible for the Golden Visa program.

  • Can I invest in real estate-related investment funds?

    After the recent law change, investors can’t purchase units in funds that are directly or indirectly linked with real estate development to obtain a Golden Visa. However, investment funds unrelated to real estate are still an option.

  • Does Portugal offer citizenship by investment in fund units?

    No, the only way for a foreigner to become a Portuguese citizen is by naturalisation. However, investing €500,000 in qualified investment fund units gives you the right to apply for the Portugal Golden Visa which, in turn, opens a path towards citizenship in five years.

  • Can I return the investment?

    Investing in fund units is a commitment that can stretch for a few years beyond receiving citizenship. If the assets have been managed well, you won’t only get your investment back but also register a profit, but that is not a guarantee.